On 27 January 2017, 7 additional countries signed the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of Countryby-Country (CbC) reports. The signing took place at a ceremony held during the second meeting of the inclusive framework on BEPS on 26-27 January 2017. Those countries are: Gabon, Hungary, Indonesia, Lithuania, Malta, Mauritius and the…
Read more
Is it Time to Expatriate? Your Neighbors Are.
The Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency “Expatriated” during the fourth quarter of 2016. The number of published expatriates for the quarter was 2,365, bringing the total number of published expatriates in 2016 to 5,411. The total for the 2016 year breaks…
Read more
Former Marine Denied Foreign Earned Income Exclusion for Failure to Make Election Timely
The Tax Court has concluded that a taxpayer wasn't entitled to a foreign earned income exclusion under Code Sec. 911(a) for the tax year at issue, because he failed to make a timely election under Reg. § 1.911-7(a)(2)(i), which provides that if the taxpayer is filing a late return and owes income tax after taking…
Read more
Third-Party Summons Rules Applies To Data on Taxpayer's Marijuana Business
The district court has made several rulings regarding Code Sec. 280E, the Code section that disallows deductions in carrying on a trade or business that consists of trafficking in controlled substances. One such ruling was that Code Sec. 7609(c)(2)(E)(i), which provides an exception to the Code's third-party summons rules where the summons is issued by…
Read more
